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UNITED STATES v. GENSER

Nos. 76-2623, 76-2624.

595 F.2d 146 (1979)

UNITED STATES of America, Appellee, v. Lester GENSER and Lawrence Forman, Appellants.

United States Court of Appeals, Third Circuit.

Decided March 9, 1979.

Attorney(s) appearing for the Case

Robert J. Del Tufo, U. S. Atty., Maryanne T. Desmond, Asst. U. S. Atty., Newark, N. J., for appellee.

Irving R. Segal, James D. Fornari, Susan K. Herschel, Schnader, Harrison, Segal & Lewis, Philadelphia, Pa., for appellants; Zuckerman & Aronson, Newark, N. J., of counsel.

Before SEITZ, Chief Judge, and BIGGS and HUNTER, Circuit Judges.

Submitted Under Third Circuit Rule 12(6) December 22, 1978.

OPINION OF THE COURT

SEITZ, Chief Judge.

In this aspect of these appeals we must examine the substantive and procedural implications of the Supreme Court's decision in United States v. LaSalle National Bank, 437 U.S. 298, 98 S.Ct. 2357, 57 L.Ed.2d 221 (1978), which described the limits of the Internal Revenue Service's authority to issue civil summonses...

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